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HomeMy WebLinkAbout2023CV30130 - City Of Fort Collins V. Directional Plus, Et Al. - 018 - Mastec Motion For Leave To Amend Answer And File CrossclaimDISTRICT COURT, LARIMER COUNTY, COLORADO Address: 201 LaPorte Ave., Ste. 100 Fort Collins, CO 80521 Plaintiff: CITY OF FORT COLLINS v. Defendants: DIRECTIONAL PLUS, LLC, and MASTEC NORTH AMERICA, INC. Attorneys for Mastec North America, Inc.: Ivan A. Sarkissian, #28817 Joseph F. Nistico, III, #49909 McConaughy & Sarkissian, P.C. 4725 S. Monaco Street, Suite 200 Denver, CO 80237 Telephone: (303) 649-0999 Facsimile: (303) 649-0990 isarkissian@mslawpc.com tnistico@mslawpc.com ▲COURT USE ONLY▲ Case Number: 2023CV30130 Division: 3B DEFENDANT MASTEC NORTH AMERICA, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CROSSCLAIM AGAINST DEFENDANT DIRECTIONAL PLUS, LLC Defendant, MasTec North America, Inc. (“MasTec”), by and through its attorneys, McConaughy & Sarkissian, Professional Corporation, respectfully submits this Unopposed Motion for Extension of Time to File Crossclaim Against Defendant Directional Plus, LLC and states as follows: 1. Certificate of Conferral: In accordance with C.R.C.P. 121 § 1-15(8), undersigned counsel has conferred with counsel for Plaintiff and Defendant Directional Plus, LLC (“Directional Plus”), who do not oppose the relief requested herein. DATE FILED: August 25, 2023 3:54 PM FILING ID: 76AC065BFF3F1 CASE NUMBER: 2023CV30130 2 2. Where, as here, a motion to extend a deadline is brought “before the expiration of the period originally prescribed[,]” the Court may extend the deadline “for cause shown.” C.R.C.P. 6(b)(1). 3. Pursuant to the Court’s order dated August 20, 2023, the deadline for MasTec to file an Amended Answer and Crossclaim Complaint is August 25, 2023. 4. MasTec seeks this extension due to the press of business, including complying with pre-trial deadlines for two upcoming jury trials, and to allow adequate time to prepare MasTec’s Amended Answer and Crossclaim Complaint. 5. The requested extension is not intended to delay these proceedings and will not prejudice the parties, as neither Plaintiff nor Directional Plus object to the proposed extension. WHEREFORE, Defendant MasTec North America, Inc. respectfully requests that the Court grant this Unopposed Motion and extend the deadline for MasTec to file an Amended Answer and Crossclaim Complaint through August 29, 2023. Dated this 25th day of August, 2023. Respectfully submitted, McCONAUGHY & SARKISSIAN Professional Corporation SIGNATURE ON FILE WITH MCCONAUGHY & SARKISSIAN, P.C. By: /s/ Joseph F. Nistico, III Ivan A. Sarkissian, #28817 Joseph F. Nistico, III, #49909 Attorneys for Mastec North America, Inc. 3 CERTIFICATE OF SERVICE I hereby certify that on this 25th day of August, 2023, a true and correct copy of DEFENDANT MASTEC NORTH AMERICA, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE CROSSCLAIM AGAINST DEFENDANT DIRECTIONAL PLUS, LLC was filed with the Court and served via CCEF and addressed to all active counsel of record on CCEF’s service list. /s/ Kelly Spicer SIGNATURE ON FILE WITH MCCONAUGHY & SARKISSIAN, P.C.